Environmental Defense Institute
P.O. Box 220 Troy, Idaho 83871-0220 Phone 208-835-6152 / Fax 208-835-5407
Comments
on
Centers for Disease Control
INEEL Dose Reconstruction Health Study
Task
Order 5
September 2000
Draft Report
March 5, 2001
submitted on behalf of
Environmental Defense Institute
by
Chuck Broscious
Background
The Environmental Defense Institute (EDI) received no official notice from Centers for Disease Control (CDC) that the September 2000 Draft Task Order 5 report was available. Only recently did EDI hear anecdotally that the report was available and requested a copy from CDC, only to receive the report after the comment period had expired. This lapse of public outreach is indicative of CDC's lack of commitment to public involvement in its research findings.
The most formidable obstacle to independent analysis of Department of Energy (DOE) operations is access to information. Reviewing the CDC Task Order 5 (TO5) (produced by Risk Assessments Corp.) on the Idaho National Engineering and Environmental Laboratory (INEEL) Dose Reconstruction Study is an example of this fundamental paradigm. The veil of secrecy established at the beginning of the nuclear age, continues to shroud INEEL's operations from the public's eye. Independent review of CDC's Task Order 5 report is therefore fundamentally crippled from exercising the most basic of scientific processes required to validate any finding - equal access to the information so CDC's analysis can be replicated. CDC is not troubled by this secrecy paradigm and in fact is actively maintaining it. Under these circumstances, CDC cannot claim an unbiased scientific approach to its research.
For instance, in 1994, responding to EDI's inquires, CDC publicly announced that Operation Bluenose did not involve radiation releases and, therefore, was irrelevant to the INEEL dose reconstruction study. CDC was later forced to recant this statement after censored FOIA documents received by EDI clearly documented that Operation Bluenose involved radioactive releases from INEEL and other sites. Another instance in 1997, CDC, DOE, and Navy advocated against an Environmental Defense Institute and INEEL Health Effects Subcommittee (IHES) supported recommendation requesting an index of classified documents deemed useful by EDI as a check against CDC's request to DOE for declassification of documents relevant to the study. The agency's argument revolved around the "fact" that an index did not exist and extensive resources would be needed to create one and that it would not be useful in their view in a dose reconstruction study. Infact, CDC stated on the record that resources diverted to generating an index of classified documents would come out of DOE's budget allocations to CDC and therefore restrict CDC's health study. [See IHES meeting verbatim transcript 10/11/97]
After lengthy appeals, EDI FOIA requests produced the INEEL index of classified documents, and it was revealed that CDC had a copy of the index as early as 1992, but did not want EDI or the public to have access to it. These are but a few examples of how CDC actively blocks public access to information related to radiation releases from INEEL.
Since its inception in 1989, EDI, has filed dozens of FOIA requests with DOE's Hanford and Idaho Operations as well as the U. S. Air Force related to radiation releases from INEEL. DOE launched numerous efforts to block EDI's FOIA requests starting with denial of fee waiver provided by law and attempted to impose copy charges of $1,200,000. When that tactic failed under appeal, DOE tried to deny the FOIA's on the basis that EDI did not have the technical resources to understand the information nor the ability to disseminate the information to the general public. That tactic also eventually failed on appeal. Finally, DOE, the Navy, and the Air Force (especially over Operation Bluenose releases) have hunkered down behind the "national security" barricade by claiming that release of these fifty-year-old secret documents on radiation releases would compromise this country's national security. Consequently, what few documents that are released under FOIA, have major sections missing and/or major portions are censored ("blacked") out. The censors claim that: "These portions contain information that remains currently and properly classified in the interest of the national security.... the authorized disclosure of this information could reasonably be expected to cause serious damage to the national security." [USAF 29 Jan 1999]
Other censor tactics are blacking out page numbers so it is impossible to determine if the whole document was released. Still other censor tactics are to declassify a cover letter with deletions and not include the attachment that contains the important information. Of the 158 documents requested in EDI's 1998 "Bluenose" FOIA, only 41 have been declassified and those are heavily censored to the point of being useless. See Attachment 1 on Operation Bluenose for more discussion. Reviewing the Attachment 4 FOIA title listings can leave little doubt of the connection of Hanford and INEEL's involvement in Bluenose releases. CDC simply cannot bury its collective agency head in the sand and ignore this program in its INEEL TO5 analysis.
Given this piecemeal and at best sketchy access to information, it is nearly impossible for EDI to review the full range of operations at INEEL that may have resulted in major releases of radiation into the environment, which is the subject of CDC's INEEL Dose Reconstruction Study. Specifically, undue focus on the "RaLa" Runs as being the only "green" reactor fuel-reprocessing program that released large quantities of radiation into the environment during the early years is highly questionable. CDC acknowledges as much by stating: "Interestingly a high release of I-131 (about 50 curies) on Saturday, March 1, 1958 was not associated with a RaLa run and points out the difficulty of completely separating out the releases from the RaLa operations from other processing activities at the ICPP during that time." [CDC@20]
Green fuel is a term used to describe reactor fuel that has not "cooled" first before being reprocessed. "Cooling" in water pools, allows short-lived fission products in the fuel to "safely" decay before reprocessing. The popular term "RaLa" is a misnomer since the research, development, and production is centered on the isotope barium-140. Radioactive Lanthanum-140 is the daughter of barium-140, which was used in radiological warfare because it killed people through radiation exposure without destroying infrastructure. Based on limited documentation available to EDI, some 502,000 curies of Ba-140 produced at ICPP was shipped to Los Alamos for open-air radiological warfare tests. Other secret programs involving "green fuel" reprocessing occurred before, during and after the time of the RaLa Runs and therefore must also be analyzed.
INEEL Green Reactor Fuel Reprocessing
What few pieces of the puzzle EDI does have contradict some of the CDC's Task Order 5 (TO5) findings. For instance CDC claims, "there were about 78 separate [RaLa] Runs from 1957 through 1963." [CDC@19] Nowhere in the TO5 Report is there an apparent chronological listing of the RaLa Runs CDC evaluated either in the report text or the CD Rom spread sheet tables. CDC provides an incomplete RaLa Run list in the "Routine Releases" spreadsheet under the section "Reported releases from the ICPP during RaLa Operations" however the list only shows releases by the month and year totals from February 1957 through December 1961. There is no explanation why 1962 and 1963 were not listed. CDC offers another Episodic "RaLa Run Releases" in a jumbled list of only 14 runs between February 24 1957 and February 6, 1959. Even combining these two lists leaves huge gaps in the RaLa history that CDC makes no attempt to explain. The spreadsheet tables offer no "legend" to explain all the acronyms and varying units of measure. Given the importance of the RaLa Runs, this TO5 reporting flaw makes it impossible to evaluate and/or replicate CDC's analysis. Even DOE's Historical Dose Evaluation (HDE) offered a chronological run-by-run listing of the RaLa history, which unfortunately is also incomplete because it starts in 1957, long after the RaLa hot runs started in 1956.
CDC states: "We compiled the daily reported releases of I-131 (and I-132 when it was reported) from March 11, 1957 through June 14, 1963 to determine the best approach to screening the releases from the ICPP during the RaLa Runs." [CDC@20] If this occurred, CDC offers no evidence of it, and again the start dates do not include the early RaLa Runs. Additionally, CDC offers no discussion of the reliability of the INEEL reporting of releases. When CDC misses such important radiation releases how can the public attribute any credibility to the entire report?
Phillips Petroleum, then operating the Idaho Chemical Processing Plant (ICPP), documents gained through EDI FOIA’s report extensively about "hot" RaLa Runs as early as November of 1956. [PTR-185] There were at least five RaLa Runs between November 1956 and the following February 1957, when CDC claims RaLa started. These early runs released more Iodine-131 than later runs and therefore must be included in CDC's analysis. Pilot plant, and cold fuel RaLa Runs are understandably not included.
In INEEL Phillips reports that covered the first five runs in detail note that these RaLa runs, produced 118,033 curies of Ba-140 product that was shipped to Los Alamos from processing green fuel containing 243,840 curies of Iodine-131. The reports also note: "There are indications that considerable iodine activity passed through the scrubber. Smears indicated the presence of iodine in the stack. AEC site surveys indicated that local rabbits showed significant increases in thyroid radiation count immediately following Runs 3, 4, and 5. Since gases from the runs were not collected and sampled it is not known how much activity was discharged from the stack. If known, this amount would raise the Runs 3, 4, and 5 iodine balances." [PTR-185 @19]
The last RaLa Run appears to be in April 1963. Documentation on this of the above-cited information was available to CDC since the May 1998 when the agency received a copy of EDI's Citizens Guide to INEEL. [See Guide at 30] If Phillips was uncertain about the accuracy of Iodine releases, CDC should not rely on the Phillips recorded data in its assessments.
One 1955 Phillips "RaLa Pilot Plant" reports states: "RaLa, MTR-B, MTR-RaLa, and DORP are synonymous terms used by various sites to designate barium-140 production. The term 'RaLa' is an abbreviation for Radioactive Lanthanum-140, which is a decay product of barium-140. RaLa as used in this report refers to all phases of barium-140 production from development to actual productions facility operations." [IDO-14344@10] This quote could suggest the undue reliance to the reference "MTR" in terms of it being generic RaLa and not necessarily directly tied to the Materials Test Reactor fuel.
The Hanford Connection
CDC dismisses EDI's contention that there was a Hanford connection with the ICPP RaLa process. The TO5 report states: "We searched for an reviewed documents from Hanford and the INEEL for information to clarify Hanford role. The historic record clearly shows that Hanford shipped fuel slugs to the INEEL regularly. On Jan 14, 1952, a Hanford memorandum indicated that the INEEL had asked if Hanford could be able 'to can five hundred ten simulated J slugs for cold runs during the start-up of the ICPP.... these records indicate that fuel was shipped to the INEEL but after it had been cooled for weeks or months. Fuel for the RaLa runs was cooled at the most for about 2 days to limit the decay of Ba-140. These record reviews indicate that Hanford did not supply fuel elements for the RaLa processes at the INEEL." [CDC@20]
General Electric, then Hanford's primary contractor, released a report "Scheduling RaLa Shipments" that established a preciously coordinated effort between production, shipping, processing, and Atomic Energy Commission's Los Alamos bomb test schedule. The report states in part:
"A new procedure for scheduling RaLa shipments has been adopted by the Reactor Section. It establishes a method for the consideration of RaLa cost factors and makes possible the selection of RaLa material under exact optimum conditions." "Since the half-life of RaLa (40 hours is considerably shorter than that of the parent Ba-140 (12.8 days), the RaLa decay rate becomes approximately equal to its formation rate (or the Ba-140 decay rate) which in turn is dependent on barium concentration. Therefore, the concentration of RaLa is directly dependent on the concentration of the parent Ba-140; and barium content is used as the basis for the entire RaLa program. The short half-life of the RaLa product has important effects on RaLa procedure. Due to its rapid decay rate, Ba-140 concentration approaches saturation in 'green metal' soon after the metal is charged into the reactor. For this reason, metal shipped, as RaLa is normally 'green' metal charged on the last outage previous to the RaLa shipment. Due to the short half-life of the RaLa product, rapid handling and processing of the discharged material is imperative. Once a reactor is shutdown and metal is discharged for the RaLa program, this material must be shipped, processed, and forwarded to the destination as quickly as possible so as to minimize product depletion due to decay. For this reason, the dates and times of RaLa shutdowns are routinely adjusted to shipping schedules. Requests for RaLa shipments are received in the form of a specified amount of RaLa product to be shipped on a certain date. Amounts requested are specified in curies. Sufficient additional product must be shipped to allow for decay so that the specified amount will be obtained as final product following the separation process. The Production Scheduling Group of the Reactor Section is required to interpret and comply with this request under conditions of optimum economy as follows: 1.) Schedule a RaLa shutdown at one of the reactors on the shipping date specified by the AEC. 2.) Schedule the discharge of certain regular metal tubes, and designate certain slugs from these tubes to be shipped as RaLa material. 3.) Perform the administrative functions of accountability, coordination, and revision of the Reactor Section outage schedule as necessary to accommodate the shipment." "Evaluating the terms appearing in this equation [for determining how many slugs to ship], the quantity X is specified. One week of decay time is allowed for shipment and separation, fixing t2 at 7 days. (If for any reason the shipment is not made immediately on the shut-down day, additional decay time is allowed accordingly.)" "The [Non-Hanford] off-site separations cost should be included in cost considerations; however, necessary data has not been available and therefore RaLa shipments are being scheduled on the basis of minimum [Hanford Atomic Products Operations] HAPO cost." [HW-32594 or HAN-56557]
EDI has copies of about fourteen heavily censored declassified Hanford documents dated between 1953 and 1958, that report on over 274,000 irradiated enriched uranium slugs shipped to the ICPP, also called Arco because of the proximity to the town of Arco to INEEL. One 1955 General Electric Hanford Atomic Products Operation (HAPO) report titled "Shipment of 'J' Slugs to Arco" states: "Hanford will have irradiated J material on hand to permit shipments to resume on March 3, 1955. Presently there are approximately 700 extruded J slugs in the Hanford reactors these slugs will be identified and shipped to Arco separate from the cast material. The reference letter states that a maximum of six hours will be allowed for unloading, loading, and decontaminating of the four casks without a delay penalty. It appears feasible to complete this work, under ideal conditions, within the allotted time; however delay penalties would be expected." [HW-35520] Why the tight schedule and "penalties" if there was not a product decay factor?
Other 1958 Hanford documents describe an extensive transportation system of two Garrett Freight Line flat bed truck convoys with each truck carrying two casks for a total of four casks each shipment. These convoys were in constant circulation between Hanford and Arco leaving every Monday and Thursday. [HAN-68946] "The first shipment of irradiated C slugs is scheduled to leave Hanford on Monday, March 29, 1954, and will arrive at Arco on Tuesday, March 30. This will result in four buckets [casks] being loaded at Hanford, four buckets being unloaded at Arco, and four buckets enroute at any one time." [HAN 54108] Another 1955 Hanford report states: "The trucks will be available at Hanford at 8am on Monday and Thursday mornings for unloading, loading, and decontaminating the four casks. A maximum of six hours will be allowed for this work without incurring a delay penalty." [HAN-58025] Again, what are the rush and resultant penalties for delays if product decay was not an issue?
Hanford was heavily involved not only in sending irradiated enriched uranium slugs to Arco, but tracking the releases that resulted from the ICPP reprocessing of Hanford slugs. A 1956 General Electric report states: "It has been Idaho's policy to send us reports of dissolution of Hanford slugs only for those months in which Hanford slugs were dissolved. As a consequence, we are not in a position to state authoritatively, but only by inference, that there have been no releases during a given month, until the next report of dissolution is received." [HAN-63584]
A heavily censored INEEL Phillips Petroleum "Gas Release Report" to the AEC notes: "The Hanford NP material charged to the ICPP dissolution equipment during the month of August 1956 is listed in the attachment to this letter. The gas plant was in operation during August and the amount of Kr-85 collected is reported in the letter giving Kr-85 production as calculated from the chemical measurement data, isotopic distribution, and irradiation history." [HAN-63688]
Numerous 1956 Hanford documents titled "Reporting Bluenose Releases" [HAN-63688] based on "reports on the dissolvings at the ICPP" make the undeniable connection between Hanford slugs and INEEL's participation in Operation Bluenose intentional radioactive releases, which switched from Iodine-131 to Krypton-85 releases. See Attached Bluenose Discussion for more information.
CDC's report apparently does not acknowledge Operation Bluenose in its TO5 report, and therefore cannot be considered as an adequate review of INEEL operational releases to the environment. Whether or not Hanford slugs were used in the ICPP RaLa Runs or other "green fuel" reprocessing programs at the ICPP is important because if CDC is forced to do a physical reconstruction of the ICPP releases (like what eventually occurred with the Hanford Dose Reconstruction Study), then the irradiation history of the fuel burn-up and reactor power levels will be needed. That documentation must be collected and preserved for that future research. See Attachment Estimating ICPP Source Terms.
Other Comments
CDC's use of a CD Rom to provide substantiating data in support of the written text of the TO5 Draft Report has the potential to be very useful. In its present form however it is of little use given that there is no apparent index provided either in the written report or on the CD that offers the reviewer a "road map" with the appropriate and essential explanation of what is in each of the files and "legends" explaining what the spreadsheet columns represent. Most spreadsheet software offers the capacity to show headers and/or footers to explain the contents of the file. One is left with a laborious process of "trial and error" going through each individual file to distinguish the purely data files from summary files. Even when a summary file for a given release event is located, one finds huge release event gaps where there is no apparent explanation for the gaps. Some summary files offer total release numbers while others do not. An extreme example of this deficiency is in the SPERT and SNAPTRAN files in the CD. These were major release events that a reviewer is left scratching his head wondering how CDC incorporated the data into the overall analysis.
The excessive decay time and distance assumptions used in calculating the doses go to the very heart of violating IHES's fundamental requests and independent critics of DOE Historical Dose Evaluation (HDE) for using the INEEL fence line as a critical means of reducing the dose to the "unbadged" soft drink and phone repair person in the immediate vicinity of the release.
EDI applauds the constructive criticism offered by IHES members Al Tschaeche and Doug Wells especially related to the inappropriate use of NCRP 123 methodology to estimate episodic release doses when the NCRP has specifically articulated that the model is not intended for accidents. Additionally, Peter Richards critique puts the spotlight on numerous other deficiencies of the TO5 Report that EDI supports.
CDC's website on INEEL Dose Reconstruction does not offer the document database or links to the document database used in their studies. This is a serious block to independent researchers evaluating the TO5 report because it is the fundamental informational basis of the report. The database is posted but separately and not linked to the main INEEL website. The point being it is not readily accessible even to this researcher who failed to access the INEEL document database after repeated attempts. Peter Richards later supplied the website address not provided by CDC.
A random search of the hidden CDC document data base of their website revealed that none of the documents cited in EDI's analysis were in the data base as EDI previously noted when the data base was first released. CDC has a scientific obligation to explain these major discrepancies and why documents EDI has revealed are not in the database. The CDC database search engine is fixed to predetermined categories, which is not useful if a person is seeking documents related to a particular program.
The serious problem of document destruction is not apparently mentioned in the TO5 Report, and therefore represents a major deficiency. For more discussion of the issue see Attachment 4 below.
CDC's states that "The release data measured since the mid-1970s were of good quality and may be sufficient for dose reconstruction...."[TO5@i] This is an absurd statement especially in view of revelations of INEEL contractors falsifying radiation reporting documents. [See Mock/Lebow v. Lockheed] CDC's statement that tritium is the only radionuclides detected beyond the INEEL border is false given that Iodine-129 was detected in two USGS wells seven miles south of the border. [TO5@ i&51] The choice of Rout 20 as an "on-site" location does not meet the IHES recommendation of unbadged phone repairperson at the release location. CDC appears to have overlooked the ICPP 10/58 criticality that released 1,200 curies. [ERDA-1536] The report states that the primary release sources were reactor and reprocessing operations fails to recognize the major release source of the Calciner high-level waste incinerator.
Summary
The whole process of substantive public review of CDC's INEEL Dose Reconstruction Study remains perverted by the continued secrecy and blocks to FOIA’s by individuals and public interest organizations. CDC is making no credible effort to change this untenable restriction to the essential information needed to verify the agency findings. CDC, as previously stated, actually is actively engaged in blocking public access to the relevant information. Additionally, CDC is making no effort to safeguard relevant documents so that they are not destroyed by DOE and its contractors.
As an activist in the early years of the Hanford Dose study (HEDR) and in later years an avid tracker, there are lessons to be learned. Initially, DOE and contractor Bechtel (Pacific Northwest Labs)(PNL) did all the Hanford source terms for the health study. Public confidence justifiably deteriorated claiming DOE could not investigate itself. The public summarily dismissed the early PNL Green Run reports. Subsequently, a physical reconstruction of the Green Runs was conducted which resulted in a 70% increase in Iodine-131 Green Run releases. Public distrust continues on the HEDR studies, and ultimately resulted in large class-action suits against DOE that are still being litigated. My discussions with the technical consultants for the Hanford plaintiffs suggest dramatic increases of the Hanford releases.
A similar process is evolving at INEEL where CDC is reviewing DOE's INEEL Historical Dose Evolution. Public skepticism is again justified when CDC fails to incorporate public and INEEL Health Effects Subcommittee recommendations. For instance, the proposed (quick and dirty) review of the RaLa runs at INEEL will again be summarily dismissed by the public unless a comprehensive physical reconstruction is conduced. This means: 1) documentation of the fuel type and composition; 2.) the power level of the reactor the fuel was interned in; 3.) the cooling time between when the fuel was removed from the reactor and when it was reprocessed; 4.) the emission control system in place at the time, to establish the release fractions. Repeating the failed DOE efforts of the past at Hanford will only further entrench public opposition to the proposed RaLa Run review. The message to CDC is "do it right the first time" do not repeat the mistakes of the past at Hanford.
On the whole, CDC Task Order 5 report contains fatal flaws that if not corrected will lead to even greater distrust and public recognition of the lack of the federal government's ability to investigate itself. Class-action lawsuits against DOE and its INEEL contractors are inevitable. If the Hanford scenario is repeated at INEEL, the independent scientists hired by law firms representing downwinders will again show CDC's political modus operandi dominated over credible science.
Attachment 1
Secrets Lies and Bluenose Releases
The old adage "what you don't know can't hurt" does not apply to toxic radioactive substances released into the environment by the United States government during secret military operations. These releases continue to affect the health of tens of thousands of Americans living in the shadow of nuclear weapons' production and testing sites.
This article explains what is currently known about one such military discharge program of radioactive substances. The information within it has been gleaned from my reading of hundreds of U.S. documents released under the Freedom of Information Act (FOIA). Many more documents, however, continue to be shrouded by a cloak of secrecy. The U.S. government's insistence that documents over forty-years old pose a threat to national security does not meet the laugh test much less the most basic test of an open democratic society.
In the late 1940's and 1950's, the United States Atomic Energy Commission (AEC) and the Air Force implemented a secret program code-named Operation Bluenose. The program's objective was to determine the Soviet Union's plutonium production levels in order to evaluate the extent of their nuclear weapons' capability. The general idea behind Bluenose was to analyze fission-product gases released into the atmosphere during the Soviet Union's reprocessing of reactor fuel.
Although the Air Force had developed a high altitude spy play, called the U-2, that could overfly the Soviet nuclear production sites and conduct reconnaissance, it wanted to verify not only that the Soviets were producing plutonium but also how much was being produced. To accomplish this, the Air Force had to refine the fission air sampling process used the U-2 planes. Operation Bluenose was created to achieve this goal.
In order to correlate fission product sample data with what was being produced on the ground, a simulated experiment was needed. The solution: run the U.S. nuclear production plants "Soviet style" and overfly them with U-2's. Since the AEC knew the U.S. plutonium production rates for each plant on an hourly basis, the monitoring sample, collected by the U-2's flying at 100,000 feet, could be correlated to a specific production rate.
To run the U.S. plants "Soviet style" required some adjustments to the differences between Soviet and U.S. plants. In the rush to catch up to the U.S., the Soviets were saving time by reprocessing "green" reactor fuel, as opposed to first cooling the fuel for a year before reprocessing. Cooling the fuel, in water pools, after extraction from the reactor allows short-lived fission by-products, like the highly toxic Iodine-131, to safely decay so less is released into the environment. In the early years of the nuclear arms' race, both countries reprocessed "green" fuel; however, the Americans installed some minimally effective filters to reduce emissions and gradually increased the fuel cooling time, except for secret projects like Operation Bluenose. These projects benefited from the release of large amounts of fission by-products and thus allowed the U-2's to more easily calibrate the air sample with the amount of nuclear fuel being processed on the ground.
This is clearly revealed by documents gained through FOIA in 1986 by the Hanford Education Action League. These documents describe how, in an effort to satisfy military intelligence needs, the AEC recommended that other tests be conducted at Hanford that would release more radiation and also asked that plant filters be disconnected. Clearly, the AEC was trying to simulate at the U.S. plants was happening in the Soviet Union by processing "green" fuel. The move to "green" fuel was also done for nuclear processing runs at Oak Ridge, Tennessee and the Idaho National Engineering and Environmental Laboratory's (INEEL) so called "RaLa Runs" during the 1940s and 1950s, despite the consequences of increased radiation releases to the public health.
While working on the Hanford Downwinders class-action lawsuit, Owen Hoffman, President of the SENES Oak Ridge Center for Risk Analysis, determined that approximately 900,000 curies of Iodine-131 were released by the AEC's Hanford plants between 1944 and 19547, a period known as the Hanford Green Runs. This amount is 150,000 curies more than "official" estimates from the Center for Disease Control (CDC), estimates generated by the agency's Hanford Dose Reconstruction Health Study. The infamous Three-Mile Island meltdown released about 15 curies of Iodine-131. Clearly, the most serious nuclear accident in U.S. history pales in comparison to these Hanford releases, but they are not the only ones of similar significance.
Based on his research for the Oak Ridge National Laboratory Health Study, Hoffman also believes the RaLa Runs (the Oak Ridge equivalent of the Hanford Green Runs) are grossly underestimated by the public health agency. Although the RaLa Runs processed green reactor fuel for a different purpose: to extract isotopes used for AEC radiological warfare experiments, they were also used by the Air Force to meet the needs of Operation Bluenose.
The Ra La program was transferred from Oak Ridge to INEEL where similar huge releases of radioactivity occurred. Operation Bluenose, the Hanford Green Runs, and the INEEL RaLa runs, conducted between 1954 and 1963 were distinctly separate programs. The Air Force, however, opportunistically used them all in their Bluenose over flights.
Initially, the U-2 planes sampled for Iodine-131, but in later years, switched to Krypton-85 as the "signature of reprocessing" because it dispersed into the stratosphere where the U-2's were forced to fly to avoid being shot down by the Soviets. The switch to Krypton-85 has been confirmed in the partially declassified Operation Bluenose documents, obtained under the FOIA. From a public health perspective, Krypton is not as toxic as other fission by-products. However, its releases are indicative of large concurrent iodine, strontium, cesium, and dozens of other highly toxic radionuclides that do pose significant public health hazards. By knowing the Krypton releases, it is possible to estimate the amount of iodine and other fission product releases. Therefore, this information must be fully declassified to meet the public's right to know what pollutants were released.
The environmental emissions data on Operation Bluenose, Ra La, and other secret military programs remain classified forty years later despite public demands for full disclosure. The importance of declassifying this information lies not only in the public's right to know what they were subjected to without their consent but also in establishing the government's liability to compensate those who suffered from radioactive releases.
Robert Alvarez, former senior Department of Energy (DOE) policy advisor, claims that the rationale for keeping radiological release data classified on the grounds that it could be used to estimate U. S. plutonium production is no longer valid and a clear-cut abuse of secrecy. Arjun Makhijani, head of the Institute for Energy and Environmental Study, agrees, adding that U.S. plutonium production rates are publicly known because of treaty disclosure requirements. Clearly, the refusal to declassify emission data cannot be supported on the basis of national security.
David Albright, Director of the Institute for Energy and International Security, is a member of DOE Secretary's Openness Advisory Committee. He thinks that continuing to classify the Iodine and Krypton releases is an unwise policy. According to Albright, no single individual DOE or Air Force declassification officer should decide what radiation emissions to declassify and what to keep secret. Albright also contends that the amount of Krypton releases is known. Frank Von Hipple conducted a publicly available study for the International Atomic Energy Commission (IAEC) for all nuclear production facilities worldwide. The IAEC developed its own Krypton tracking system to verify zero nuclear bomb production under the Nuclear Non-Proliferation Treaty. Despite the IAEC disclosures, the information is not detailed enough to isolate individual nuclear production site releases, information vitally needed to establish the amount of radiation released for specific plants during specific periods. Dose reconstruction health studies require fission by-product environmental release data from a specific nuclear plant, sometimes on an hourly basis, so it can be merged with meteorological data, thereby, allowing scientists to determine what pollutant went where and who was effected. This is why detailed operating history and throughput of each nuclear production plant must be declassified.
Secret document title lists, obtained during the Hanford Environmental Dose Reconstruction Study, confirmed that the INEEL was involved in Operation Bluenose in the 1950s. Starting in 1991, the Environmental Defense Institute filed FOIA requests to DOE Hanford INEEL and the Air Force for documents related to the Bluenose project. Although Hanford sent eight of the twenty-eight documents requested, portions of these reports were "blacked out" or otherwise censored because, according to the government, release of this information "would compromise national security." The data quantifying radioactive releases were blacked out as well as page numbers, so it is impossible to determine if pages were deleted and what the magnitude of the release was.
The CDC is currently conducting an INEEL Dose Reconstruction Health Study to determine what radioactivity was released from the site over its operating history. Although it would seem as if the government is doing all it can to answer the public's questions, history proves otherwise. As a member of CDC's INEEL Health Effects Advisory Committee at the time, I was shocked when, in 1994, the CDC publicly announced that Operation Bluenose did not involve radiation releases and, therefore, was irrelevant to the dose reconstruction study. CDC was later forced to recant this statement after censored FOIA documents clearly demonstrated that Operation Bluenose involved radioactive releases.
The CDC also blocked its own Advisory Committee from recommending that DOE release an index of classified INEEL documents (it was the Hanford index that first disclosed the existence of Operation Bluenose). The INEEL index was the only way the public could independently determine if the CDC was accessing all relevant information needed to establish the INEEL radioactive releases, particularly, Operation Bluenose and the Ra La Runs.
CDC's contractor confirmed that in October of 2000, approximately 1,254 boxes of documents related to INEEL's radiological releases were destroyed. These boxes, achieved at INEEL and the Seattle Federal Information Center, contained millions of pages of information that has been lost forever. Hanford also acknowledged twenty-seven "lost" (or perhaps destroyed) Bluenose documents. The DOE's systematic destruction of this information means we may not have anything substantive left to uncover under the Freedom of Information Act; the American public may never know the whole truth. Allen Benson, author of Hanford Fallout, the first comprehensive analysis of the Hanford Green Runs says no federal agency can be trusted to tell the truth about U.S. radioactive releases. As a scientific consultant on the Hanford Downwinders class action suit, Benson believes that the only hope lies in well financed litigation that can bring in independent scientists to reveal, through court ordered discovery, what harm the public was really subjected to from the government's negligent actions.
Operation Bluenose is only one of dozens of major nuclear releases to the environment that caused serious harm to those living downwind of this nations' nuclear weapons' production facilities. Continued denial of federal agencies to declassify information needed to reveal the truth about what hazards we are being subjected to without our consent is a travesty of democracy. The only national security issue at state here is the American public's shattered confidence in our government's willingness to put health and safety above minimization of liability for past negligence.
Attachment 2
RaLa Process Runs
"The term "RaLa" is an abbreviation for Radioactive Lanthanum-140 which is a decay product of barium-140. RaLa as used here refers to all phases of Barium-140 production from development to actual production facility operation." [IDO-14344 @10] The Three Mile Island reactor accident, considered to be America's worst nuclear accident, released 15 curies (Ci) of Iodine-131. [Benson, p.2] Yet, RaLa fuel process runs at INEEL's Idaho Chemical Processing Plant (ICPP) produced "Radio iodine which can also be released under certain conditions amounts to 50,000 to 100,000 curies." [IDO-14532@13] The highest radioactive release period - over half of the total - occurred between 1956 and 1966 and amounted to 15,256,015 curies to the atmosphere. [ERDA-1536, p. III-7] [DOE/ID-12119 @A 55]
The Idaho Chemical Processing Plant (ICPP) conducted 11 process runs in 1953 for the capture of Krypton-85 and 113 process runs between May 1954 and February 1963 to recover Barium-140, Uranium-235, and Lanthanum-140 for the radiological/chemical weapons program. These isotopes were produced for Atomic Energy Commission's Los Alamos National Laboratory. RaLa was used to produce material, which Los Alamos used as a "substitute" for plutonium in certain types of radiological weapons tests. Barium-140 shared many of the physical properties of plutonium and could be used to disperse deadly fission products without destroying infrastructure. With a shorter half-life of twelve days it did not permanently contaminate the environs the way plutonium would with a half-live of 24,000 years. So it was a people killer weapon, not a building leveler that the nuclear priesthood was developing and testing on the residents of New Mexico.
"The government moved the RaLa project to Idaho from Oak Ridge, Tenn. because of concerns over the iodine releases connected with the processing "green fuel." The Oak Ridge plant was within five miles of the nearest site boundary, said [John] Horan who worked at the Tennessee facility during the early 1950s." [Times News(f)] In fact, a RaLa run blew up at ORNL when operators tried to produce a 100,000 curie batch of Barium-140, which resulted in a three-day plant evacuation. Recent disclosures by the General Accounting Office about radiation warfare experiments conducted at Oak Ridge on American citizens where hundreds of thousands of curies of Lanthanum were released suggests the Barium-140 came from either from Oak Ridge or the ICPP depending on the date of the experiment. According to the extremely limited documentation EDI has on the Ba-140/La-140 shipments from ICPP to Los Alamos, over 502,000 curies were sent and used in open air tests to evaluate the killing power of this radiological weapon.
"Radioactive Lanthanum-140, daughter of Barium-140 has been used as an intense radiation source for a number of years. Historically, a need has developed for increasing batches of the Barium-140 sources material with additional emphasis on increasing specific activity of the barium. The increasing demand resulted in inadequacy of facilities of the original barium producer, the Oak Ridge National Laboratories (ORNL). The more recent availability of high specific activity fuel from the [INEEL] Materials Test Reactor indicate the desirability of locating production facilities in conjunction with that reactor. In fact, a RaLa production cell was provided for in the ICPP original design of the Chemical Processing Plant [ICPP] by ORNL. The popular term 'RaLa' is a misnomer since the research, development, and production is centered around the isotope barium-140."... "At this time [1951], ORNL commenced the development of a process [at ICPP], based on irradiated MTR elements as feed material, capable of consistently yielding batches of at least 30,000 curies." [IDO-14445 @ 14]
RaLa runs were conducted at ICPP during the nine-year period of 1954-1963. During some a period in 1954-55 while the process was being developed, un-irradiated fuel was used. Between 1953 and 1963 the ICPP released 6,092,985 Ci to the atmosphere. [ERDA-1536@III-7] Discussions in this section focus primarily on pre-1957 RaLa runs because DOE has not acknowledged them in their 1992 INEEL Historical Dose Evaluation report as RaLa runs.
Acknowledged ICPP Iodine-131quantities released between 1957 and 1963 were 2,800 Ci, with the highest year being 1958 releasing 1,028 Ci of I-131. [ERDA-1536.@II-242] Internal DOE documents suggest the quantity of I-131 that may have been released in a single run was more than what DOE acknowledged for an entire year. This RaLa program is the INEEL equivalent of the infamous Hanford "Green-Runs" which also processed "green" reactor fuel. When reactor fuel is processed "green", that is, prior to a cooling period that allows short-lived radioactivity to "safely" decay, a significant amount of radioactivity is released to the environment when the fuel is processed. The ICPP emission control system during that period was very primitive. The veil of secrecy also allowed the nuclear alchemists to proceed without public notification or accountability. This secrecy persists today. DOE's 1991 INEEL Historical Dose-Assessment Report does not include nor acknowledge many RaLa runs or the 1956 Bluenose releases from ICPP. Some of the first process runs were conducted with non-irradiated simulated fuel. Full access to ICPP operations documentation is needed to accurately assess the RaLa program. It should be noted that it took nearly five years of public pressure on DOE to allow Q-clearance access to the daily fuel processing documentation at Hanford; however, all the documents are yet to be declassified. The same is true for INEEL. The Department of the Navy is a claiming jurisdiction over some of DOE's secret documents because they pertain to Navy fuel processing and they refuse to declassify the information. "The RaLa process involves the dissolution and processing of a 2-day cooled MTR [Materials Test Reactor] fuel assembly for recovery of radioactive barium-140. The operation is performed over a 24 to 36 hour period several times each year and involves about 1,200,000 curies of short-lived fission products. While 1.2 million curies is not a great amount compared to the normal processing plant operations [ICPP], the quantities of such elements as xenon, iodine and lanthanum are tremendous compared to those normally encountered; furthermore, the 1.2 million curies is contained in a solution volume of only a few liters. Xenon and krypton, which go to the off-gas, amount to about 100,000 curies and special measures must be taken to prevent unauthorized release. Radio iodine, which can also be released under certain conditions, amounts to 50,000 to 100,000 curies." [IDO-14532,p.13]
Phillips Petroleum, then operator of the ICPP, reported in the second quarter of 1957, that; "The liquid waste system operated satisfactorily except for failure to remove iodine resulting from RaLa processing". [IDO-14419,p.7] RaLa Run 002-RH originally scheduled for process on November 26, 1956, was delayed until November 30 "due to weather conditions being too adverse to permit gas release to the stack." [IDO-14414 @ 156] During run 002-RH, "Area AEC radiation surveys indicated that activity in the dissolver off-gas discharging from the stack persisted for about five minutes. During this period, the AEC sky scanner radiation instruments read maximum and then dropped to zero." [Ibid. @ 158] During this run, the Process Makeup Area was contaminated by a burst of airborne activity into the work area when the shipping pot was removed from the process cell. [Ibid. @ 45]
"The Barium-140 recovery (RaLa) at ICPP produces a separate off-gas stream, treated with extreme care because it normally contains kilocurie quantities of radio xenon and Radio iodine. The xenon is released under controlled conditions. If the weather permits, it goes directly to the plant stack. If the weather does not allow immediate release, it is held in a 10,000 cubic foot shielded gas holder until a more opportune time, or until the xenon has decayed to a low level." [ IDO-14532,p.26]
This holding tank was, however, not built and fully functional until 1958, two years after hot RaLa processing began. [IDO-14414 @ 170] Another problem, even after the off-gas holding tank was built, was that it could only hold 10 hours of operational emissions. [IDO-14414 @29&42] Since significant amounts of radionuclides continued to be released over days and weeks after the process run, the holding tank was of limited value even after it was installed.
RaLa Materials Test Reactor (MTR) fuel runs No.3 (12/56), and No.5 (2/57) contained 6,580 and 166,000 Ci of Iodine respectively. "Runs No. 3 & 5 weather conditions permitted venting all gases to the stack." [PTR-185 @6&7] Run No. 3 had significant equipment malfunctions that resulted in extensive contamination of the L Cell. "Four hundred man-hours were expended in reducing the general background radiation in L cell from an estimated 1000 R/hr to 0.3-1 R/hr." [Ibid. @45] Exposure to the decontamination workers under those conditions would be expected to be considerable.
Scrubbers were later installed as part of the off-gas emission control system. "There are indications that considerable iodine activity passed through the scrubber. Smears indicated the presence of iodine in the stack. AEC site surveys indicated that local rabbits showed significant increases in thyroid radiation count immediately following Runs 3, 4, and 5. Since gases from the runs were not collected and sampled it is not known how much activity was discharged from the stack. The stack monitor, which was put into service just prior to Run No. 4, indicated that significant iodine activity continued to be released for several days after each of the last two runs was completed. This would indicate that iodine has a tendency to plate out or deposit in lines and vessels only to be released gradually." [PTR-185 @19&20] The biological significance of the release of radioactive iodine is that the human body readily assimilates it into the thyroid gland.
RaLa Run No. 001-RP (Feb.1, 1957) which processed 38,800 curies of barium and 70,000 curies of Iodine was delayed 17 hours until the wind changed directions away from populated areas. [PTR-185,p.6] February 20, 1957 run No. 002-RP contained 166,000 curies of Iodine. [Ibid.] The reason both Runs No.001-RP and 002-RP had such high Iodine content was because the cooling time for the fuel was two and less than one day respectively. Barium-140 runs in the third quarter of 1962 totaled 61,252 curies. [IDO-14599,P.1]
"RaLa off-gas involves a two-fold problem; namely, activity hazard due to contained active iodine and xenon, and explosion hazard due to contained hydrogen. The off-gas activity is too great to permit indiscriminate venting to the atmosphere and the hydrogen concentration is in the explosive region making mechanical compression and storage hazardous." [IDO-14414 @ 170] "Consequently operation was necessarily limited to periods when the weather was favorable for stack disposal." [Ibid] In other words, the ICPP operators were reluctant to put much off-gas into the holding tank because of the hydrogen explosion potential and therefore it was expedient to release it to the atmosphere. So processing was delayed until the radiation would be blown north away from the more populated areas to the southeast.
"The [ICPP] fission product noble gases are present in the dissolver off-gases, and any not recovered go to the atmosphere. Krypton-85 in amounts up to 2,000 curies per-day could be released from power fuel processing. Comparable quantities of Krypton-85 have been released during previous operations without hazard to personnel on or off the site. This will be diluted by stack gas to 0.3 micro curie per liter [3 x 105 pCi/L] at the top of the stack, about 100 times maximum permissible [at the time] level for air." [IDO-14532 @46] These documented statements by Atomic Energy Commission (AEC), predecessor to DOE, demonstrate the cavalier attitude about releasing large quantities of radiation to the environment. Moreover, no warnings were ever offered so that the public could take appropriate measures to protect themselves and their families.
"Total Iodine present in an [one] irradiated MTR fuel assembly after two days cooling approaches 76,000 curies with Iodine-131 accounting for 28,000 curies of the total. Approximately 80 % of this iodine was expected to reach the off-gas scrubber, which was estimated to be 95% efficient in removing iodine. Thus about 3,000 curies of total iodine activity was expected to pass through the scrubber within a one hour period." [IDO-14414 @ 170] Even weeks after the fuel dissolution process is completed, iodine continues to escape. "It has been found that during quiescent conditions in the cell the iodine release will be from five to ten curies a day. Solution transfer or vessel decontamination will raise this to 20 to 50 curies per day. [IDO-14419, p.61] Considerable uncertainty exists between the design efficiency of scrubbers and the actual efficiency. See Stack Emission Section I(G). Uncontrolled iodine releases were also "escaping from centrifuges to cell off-gas which does not pass through the scrubber." [Ibid.] +[14494, p.19] The combined releases from these multiple sources were significant.
A postulated example of iodine releases applied to run number 002-RP would yield the following scenario. Run 002-RP had 166,000 ci of I-131. Using the extremely optimistic design standard of 95% efficiency of the scrubbers, and 80% release to the scrubber, and subtracting 80% from 166,000 Ci in the fuel, leaves 132,800 Ci released to the scrubber which theoretically had a 95% efficiency. That leaves 6,640 curies of iodine going out the stack over a two-day period. This figure would not include any DOE acknowledged releases escaping the centrifuges and cell off-gas system.
The above assumption scenario (non-conservative) is supported by DOE internal documents. "Approximately 80% of the I-129 is released as an airborne effluent and 20% is in the liquid effluent." [DOE/ID-12119@A-18] A 1978 DOE engineering study by Allied Chemical Idaho Operations for INEEL proposed an I-129, C-14, Ru-106 and Kr-85 filtration system for ICPP fuel reprocessing to reduce the emission of these radionuclides. "More than 99% of these volatile isotopes were assumed to be released during dissolution of the fuel rods." [ICP-1126@iv] The design was to include a matrix of filters to trap these volatilized isotopes. Should these filters fail or become plugged the system would just go back temporally to normal operation. During RaLa Run 003-RH, "Approximately 7 percent of charged iodine was found in the scrubber solution after the run was completed." [IDO-14414 @ 158] This suggests iodine release fractions in the range of 93%. "Since the current practice of releasing all airborne iodine species is acceptable, short-term releases in future reprocessing plant would be considered an inconsequential accident." [Ibid.@18]
The above discussion is supported by the 1977 INEEL Environmental Impact Statement (EIS), which stated, "The efficiency of this scrubber was low for iodine." [ERDA-1536 @ 242] The iodine content was so high in the RaLa reprocessing that the liquid waste evaporator would experience "Iodine-131 boil over during several batches when RaLa operations were in progress." [IDO-14430 @ 11] "Recent [1957] operational practices in the concentration of process equipment waste provided essentially no reliable decontamination of the condensate from iodine-131 in the feed. Many different schemes have been tried to retain iodine..." ... "These schemes were not successful in improving the iodine decontamination of the stream." [IDO-14430 @ 18] RaLa Iodine releases varied widely depending on the fuel processed and the cooling time before processing. The extremely optimistically low figures for part of the RaLa period (1957-63) offered in the EIS were 2,800 Ci. of Iodine-131 released to the atmosphere. Based on the crude emission system in use, these figures can only be considered as extremely understated. A thorough analysis of the entire process and the efficiency of the emission systems are needed to assess the probable radioactive releases.
Considerable variation existed in scrubber efficiency in removing Iodine-131 from 7% to 70% due to filter problems. [IDO-14287] These runs produced Barium-140 solutions averaging 5,400,000 R/hr [IDO-14306 @ 7] , and containing a minimum of 30,000 curies. [IDO-14445 @14] The RaLa process MTR throughput fuel had extremely high burn-up rates of 24% which generated 55,600 curies of Ba-140 as opposed to undesirable 17% burn-up fuel that only produced 38,800 curies of Ba-140 for every 168 grams processed. [IDO-14445 @21] The known hazard with reprocessing high burn-up fuel with less than a two-day cooling time was the release of volatilized iodine, ruthenium and krypton. "Ruthenium accounted for about 10% of the volatile activity other than krypton, with about nineteen times as much ruthenium coming off during the acid dissolution as during the caustic dissolution." [IDO-14445 @31]
Efforts by ICPP operators to reduce iodine releases included dilution of the post process waste and neutralization of the caustic supernate. "In the case of the caustic solution diluted thirty-fold, the maximum amount of iodine trapped from the off-gas was 0.93 percent. Material balances were good. With the caustic solution diluted only fifteen-fold, the amount of iodine trapped averaged about 1 percent."[IDO-14445 @80] Another 1958 Phillips Petroleum report discussed attempts to improve the Process Equipment Waste (PEW) iodine scrub efficiency by adding neutralizing solutions. "With no neutralization of the evaporator feed, there was essentially no decontamination from Iodine-131 in the [PEW] condensate." But even this effort "yielded a condensate which contained about 0.5 percent of the iodine from the feed." [IDO-14443 @ 16][IDO-14430 @18] This documentation suggests extremely poor performance of emission control systems to filter/ scrub out iodine prior to release to the atmosphere. "Since the curies of activity associated with these elements [iodides] is of similar magnitude to that of the barium being produced [30,000 to 60,000 curies] provisions to conduct dissolution under meteorological control may be necessary or an accumulator vessel to retain the gases for several weeks; decay prior to venting may be required, in order to avoid possibilities of area contamination or personnel exposure if dispersion of the plant stack gas is inadequate." [IDO-14308 @8] Even at very low PEW efficiency rates for iodine the condensate was still extremely radioactive because of very high curie content of the fuel being dissolved as feed. "Because the feed to this [PEW] evaporator is usually fairly high in activity, the condensate represents a significant source of activity discharge to ground from the plant." [IDO-14362 @ 8] This is a reference to waste discharged to the injection well. 1959 Phillips Petroleum reports continue to acknowledge that low iodine scrubber efficiencies of 17.9% of the calculated iodine was found in the caustic and less than 1% in the acid solution. [IDO-14445 @94]
Recent revelations about Hanford releases from fuel reprocessing exposed by the Hanford Environmental Dose Reconstruction (HEDR) Project are germane to INEEL. [TSP News letter, 12/92] The original estimates or 530,000 curies of I-131 released from Hanford were based on unreliable stack monitoring data. The public and independent researchers knew this was not true. After nearly five years of public pressure, DOE finally allowed access to classified daily fuel reprocessing data that allowed scientists to do a physical reconstruction of the Green Runs. The results showed an increase of 70% over previously DOE acknowledged releases of 530,000 curies Iodine-131. [Bensen @2] The key elements of the data needed for a physical reconstruction were:
1.) Cooling time of the fuel processed. Short cooling periods of hours or days rather than months means that short-lived isotope inventories such as I-131 will be much higher in the fuel.
2.) Release fractions. This figure is based on how much of the iodine present in the fuel is released to the environment. For Iodine-131, HEDR calculated the release fraction to be 90.5%.
3.) Reactor power levels of fuel used. A direct relationship exists between the reactor power level and the isotopes created in the fuel. The higher the power level, the more Iodine-131 is generated. [TSP News letter, 12/92]
4.) Fuel type and percentage U-235/Pu-239 enrichment.
HEDR now estimates Iodine-131 releases between 1944 to 1972 at about 740,000 curies which produced a 870 rad exposure to an infant born in Ringold, WA in 1943 or 1944. [Connections(a)] While working on the Hanford Downwinders class-action lawsuit, Owen Hoffman, President of the SENES Oak Ridge Center for Risk analysis, determined that approximately 900,000 curies of Iodine-131 were released by the AEC's Hanford plants between 1944 and 1957, a period known as the Hanford "Green Runs." This amount is 150,000 curies more than the "official" estimates from the Centers for Disease Control. [Hoffman]
The Hanford Health Information Network reports independent Downwinder consultant research showing Plutonium-239 releases between 1945 and 1969 as high as 1600 curies. These plutonium release estimates are based on Hanford's George Brabb's 1961 internal memo assessing fuel reprocessing (Z Plant) "and found the filtering system was not adequate to capture the vaporized plutonium oxide which was essentially in a gaseous form when released by burning. This was revealed by the fact that a significant amount of plutonium was found in the ducts of the vacuum system...even though filters protected it. This convinced me that fine plutonium was being released into the atmosphere from Z Plant." [Connections(b)] The reason for citing the Hanford problems is not to compare the release numbers but to compare the emission control system problems because the technology in any given era was the same whether at Z Plant or the ICPP.
As of this writing, CDC refuses to do a physical reconstruction of the INEEL RaLa Runs as part of the INEEL Dose Reconstruction Health Study. CDC is opting for the use of discredited DOE stack monitoring data. This is another deliberate attempt by CDC to understate the radiation release estimates in the hope that the government's liability exposure will be minimized. There are extremely important "lessons learned" from the Hanford studies that the public justifiably wants applied to the INEEL studies.
Plutonium was also extracted from the high burn-up power reactor fuels processed at the ICPP. F and V cells generated plutonium batches up to 500 grams. [IDO-14306] Plutonium emissions must be included in any analysis. The solvent burner is noted in numerous reports as a problem area. The solvent burner is used to incinerate the waste solutions used to dissolve the fuel rods containing plutonium. "Plutonium is the most bothersome contaminate" in this Solvent Burner and its "Combustion gases go directly to the main plant stack without filtering." [IDO-14287] "The solvent burner is probably the largest source of Transuranic discharged to the stack and the largest unfiltered radionuclides discharge at ICPP." [ENICO-1086 @1]
Acknowledged Chem Plant (ICPP) airborne radioactive releases during the RaLa runs (1953 through 1963) totaled 6,092,985 curies of gross beta and gamma isotopes. RaLa runs in 1959 released the highest airborne radioactivity at 1,334,902 curies of gross beta and gamma isotopes. [DOE/ID-12119@A-41][Also see Appendix listing by year] These figures do not include other INEEL facilities that were also releasing considerable quantities of radiation. For instance, the Test Reactor Area's Materials Test Reactor that provided the RaLa Run fuel rods released excessive amounts of Strontium 90 both to the air and to effluent water used to cool the reactor. [IDO-16375, p.8-9] Between 1952 and 1968 alone, the Test Reactor Area released 5,035,572 curies of radioactivity to the atmosphere. [Ibid @ A-30] Iodine-131 (around ICPP) activity in jackrabbit thyroids for the 1958 sampling period peaked in March at 709,000 d/m/g. At sixteen and twenty miles distance from the ICPP the I-131 activity dropped respectively from to 140,000 d/m/g to 93,000 d/m/g. "The highest thyroid I-131 activity ever observed at the NRTS [up to 12/58] jack rabbits was observed in two animals collected on September 10 [1958]. Their mean I-131 activity was 7.7 x 10 6 [7,700,000]." [IDO-12082(58)@78-87]
INEEL's Historical Dose Assessment Report acknowledges only 78 RaLa Runs. This DOE report list begins with what they call RaLa Run 001 in February 1-3, 1957. [DOE/ID-12119 @ A-33] Yet, Phillips Petroleum, ICPP contractor at the time, documents that, "Hot runs were begun on November 24, 1956." [PTR-185 @ 5] Although fifteen runs are acknowledged, details are given for only eight runs up to June 1957. [IDO-14414 @ 131] It must be emphasized that the Environmental Defense Institute's analysis is limited due to DOE's unwillingness to declassify all INEEL operating history documents. Therefore, the information contained here is not by any means conclusive. As of this writing, DOE has yet to declassify documents requested by CDC for both the Hanford and the INEEL dose reconstruction health studies. This is discouraging since the Hanford requests are seven years old and the INEEL requests are three years old.
Partial Listing of Early RaLa Run Fuel Content
|
Run Date |
Run Number |
I-131 Curies |
Cooling Days |
Ba-140 Curies |
|
11/24/56 |
001-RH |
? |
3 |
? |
|
11/30/56 |
002-RH |
1,260 |
4 |
3,033 |
|
12/6/56 |
003-RH |
6,580 |
1 |
18,000 |
|
2/1/57 |
001-RP |
70,000 |
2 |
39,000 |
|
2/20/57 |
002-RP |
166,000 |
4 |
55,000 |
|
4/5/57 |
003-RP |
13,560 |
2 |
28,000 |
|
5/19/57 |
004-RP |
14,500 |
? |
29,150 |
|
6/24/57 |
005-RP |
16,180 |
6 |
32,000 |
[IDO-14414][PTR-181 & 185] [IDO-14430][IDO-14419]
Incomplete Listing of RaLa Run Barium-140 Produced
|
Run Date |
Run Number |
Ba-140 Curies |
|
|
006 -RP |
? |
|
10/57 |
007-RP |
22,800 |
|
12/57 |
008-RP |
37,000 |
|
4/58 |
? |
30,000 |
|
6/58 |
? |
30,000 |
|
4/59 |
022-RP* |
23,400 |
|
|
023-RP |
10,200 |
|
|
024-RP |
24,800 |
|
|
025-RP |
23,160 |
|
|
026-RP |
19,270 |
|
|
027-RP |
23,900 |
|
6/59 |
028-RP |
26,200 |
|
10/59 |
034-RP* |
19,695 |
|
|
035-RP |
21,620 |
|
|
036-RP |
14,075 |
|
12/59 |
037-RP |
26,137 |
|
7/62 |
? |
21,085 |
|
9/62 |
? |
40,067 |
|
6/13 to 9/13/63 |
071RP to 079RP * |
200,000 |
|
Last Run 4/63 |
? |
? |
|
Incomplete total |
83 Runs |
501,920 curies Ba-140 |
* Break in run number sequence
[PTR-749][IDO-14599][IDO-14494][IDO-14512][IDO-14453]
[IDO-14430][PTR-185][PTR-181][IDO-14419][IDO14414][IDO-14410][IDO-14344]
A Phillips Petroleum RaLa Run report states, "It is assumed that inert gas fission products and iodine will be evolved in this or the following [RaLa] process step. Since the curies of activity associated with these elements is of similar magnitude to that of the barium being processed, provisions to conduct dissolution under meteorological control may be necessary, or an accumulator vessel to retain the gases for several weeks decay prior to venting may be required, in order to avoid possibilities of area contamination or personnel exposure if dispersion of the plant stack gas in inadequate." [IDO-14307@8] One can therefore get an approximate estimate of the radioactive iodine content of the fuel based on documented reports of Barium-140 produced.
Atmospheric RaLa Releases of Iodides and Beta Activity
|
Year |
Run Numbers |
Curies Released |
|
1957 |
006 through 008 |
6,399.00 |
|
1958 * |
009 " 021* |
5,334.87 |
|
1959 |
022 " 037 |
1,605.60 |
|
1960 |
038 " 049 |
246.44 |
|
1961 |
050 " 066 |
352.27 |
|
1962 |
067 " 075 |
253.26 |
|
1963 |
076 " 079 |
116.55 |
|
Totals |
79 |
14,307.99 |
[DOE/ID-12119 @ A-33] [* IDO-12082(58) lists 13 RaLa runs between 1/6/58 & 10/23/58]
A criticality (uncontrolled nuclear chain reaction) accident at the ICPP on October 16, 1959, one day after a RaLa run on the 15th increased the atmospheric releases. An AEC accident report noted twenty-one workers were exposed and offered the following description of the RaLa run.
"A RaLa run had been completed on the afternoon of October 15. This process involves the separation of radio-barium from short-cooled MTR fuel elements. Dissolution of these short-cooled elements and even later disturbance of solutions in post-run cleanup usually cause some release of fission product iodine to the process vent system. On some occasions iodine has escaped to the access corridor and PEW control room in sufficient quantity to set off the sensitive air monitor alarms in those areas. Consequently, it was natural initially to suspect that the release of apparently short-lived air-borne activity was in some way related to the RaLa equipment. This assumption seemed to have been further substantiated by the fact that: the RaLa process instruments indicated that a pressure surge had occurred, no other instruments that were observed in the hurried re-entry [after ICPP accident evacuation] showed evidence of more than minor disturbance, and high level (greater than 25 R/hr) contamination was discovered around the RaLa slug chute. High level contamination noted in the PEW control room was a reasonable consequence of the pressure surge initiated in the RaLa system." [IDO-10035 @ 16]
Another ICPP criticality accident on January 25, 1961 during the RaLa period also released radioactivity to the atmosphere. This incident (requiring full evacuation) occurred during the workweek when 251 employees were at the ICPP. The radioactive cloud traveled southwest toward Big South Butte where it stagnated for several hours before moving on south. Radiation readings at Big South Butte ranged over 200 counts per second. Readings at Central Facilities Area, 2 miles south ranged over 30 mrem. [IDO-10036@35] AEC accident report notes the following:
"Two processes in the plant handle gaseous and volatile fission
products, viz., a radio-barium separation system (RaLa process) and the
dissolver off-gas handling system. A RaLa processing run had been completed two
days earlier and no operations were being performed in that equipment. However,
post-run activities in the past had resulted in some release of Iodine-131.
Chemical changes in the process and essentially eliminated this problem, but
the associated high concentrations of short-lived fission products cause this
system to be suspect in any unidentified radiation incident." [IDO-10036@35]
Attachment
3
Estimating ICPP Source Terms at INEEL
The INEEL Health Effects Sub-committee (IHES) issued a recommendation to the Centers for Disease Control (CDC) to conduct a source term review of the INEEL RaLa Runs. At the last IHES meeting in June CDC officials indicated that they were moving forward with a RaLa Review and offered an outline of the methodology CDC intended to implement. Specifically, CDC intends to utilize DOE's stack monitoring data to quantify the source terms (what contaminates were released, how much was released and when they were released). Before launching into a discussion on this INEEL process, it is useful to review the Hanford Environmental Dose Reconstruction (HEDR) process and identify lessons learned by the public.
HEDR Source Terms
Numerous major mistakes were made and continue to be made by CDC in the HEDR process to establish radiation doses to the effected public from the emissions from Hanford. Since HEDR started some six years before the INEEL Dose Reconstruction Study, there are lessons to be learned so as to avoid repeating the same mistakes at INEEL and further undermining CDC credibility and wasting tens of millions of dollars of public resources. Initially, HEDR's focus was on Hanford's startup of its plutonium processing plants in 1944 through 1947. This period is generally called the "Green Runs" because Hanford was processing fuel shortly after it was removed from the reactor and before it cooled in water pools allowing short-lived fission products like Iodine-131 to decay. HEDR estimated in the late 1980's that approximately 441,700 curies of I-131 was released between 1944 and 1947. This estimate was based on declassified stack monitoring documents released in a Freedom of Information Act request. Few people outside DOE and CDC believed these estimates because they were based on questionable data. Finally, years later, after significant public pressure, CDC sponsored a physical reconstruction of the Green Run period between 1944 and 1947. The 1992 revised estimate increased to 685,000 curies of I-131 released between 1944 and 1947.
The partial physical reconstruction (1944 to 1947) was not extended to the 1948 to 1960 period, though HEDR estimates Iodine-131 releases between 1944 to 1960 at about 738,700 curies which produced a 870 rad exposure to an infant born in Ringold, WA in 1943 or 1944. [Connections(a)]
While working on the Hanford Downwinders class-action lawsuit, Owen Hoffman, President of the SENES Oak Ridge Center for Risk analysis, determined that approximately 900,000 curies of Iodine-131 were released by the AEC's Hanford plants between 1944 and 1957, a period including the Hanford "Green Runs." This amount is 150,000 curies more than the "official" estimates from the Centers for Disease Control. Hoffman's review focused primarily on the period between 1951 and 1960 because HEDR did not extend the thorough physical reconstruction into this period. He concludes, "the estimates of releases presented...for this period clearly represent severe underestimates of the actual releases." (1) Hoffman also notes that HEDR attempted to attribute emission control systems to processing plants many years before they were installed, thus underestimating the releases. This chronological error was also made with CDC's INEEL Phase-1 Report generated by Sanford Cohen & Associates despite protests by this author, and no attempt has yet been made to correct the errors.
INEEL RaLa Run Review
As of this writing, CDC apparently refuses to do a physical reconstruction of the INEEL RaLa Runs as part of the INEEL Dose Reconstruction Health Study. CDC is opting for the use of discredited DOE stack monitoring data. This is another deliberate attempt by CDC to understate the radiation release estimates in the hope that the government's liability exposure will be minimized. There are extremely important "lessons learned" from the Hanford studies that the public justifiably wants applied to the INEEL studies.
Documents relating to Hanford production reactors gained by the Environmental Defense Institute through Freedom of Information Act (FOIA) requests show the elaborate logistical arrangement required for the RaLa Runs at the ICPP. "The short half-life of the RaLa product has important effects on RaLa procedure. Due to its rapid decay rate, Ba-140 concentration approaches saturation in "green metal" soon after the metal is charged in the reactor. For this reason metal shipped as RaLa is normally "green" metal charged on the last outage previous to the RaLa shipment. Due to the short half-life of the RaLa product, rapid handling and processing of the discharged material is imperative. Once a reactor is shutdown and metal is discharged for the RaLa program, this material must be shipped, processed, and forwarded to its destination as quickly as possible so as to minimize product depletion due to decay. For the same reason, the dates and times of the RaLa shutdowns are routinely adjusted to shipping schedules." (2)
Other Hanford documents quantify the amount of irradiated uranium slugs shipped to ICPP. For instance one report notes that between 11/54 and 4/56 200,000 J and C Slugs were shipped from Hanford to ICPP for processing. (3) Other reports put the shipping rates at 22 kilograms per month. (4) The point in emphasizing in this discussion the extensive involvement of the Hanford reactors in providing ICPP throughput is to demonstrate the importance of this information in developing ICPP source terms via a physical reconstruction. To date, CDC is not showing any interest in utilizing this crucial information.
Both INEEL and Hanford were reprocessing green reactor fuel using sodium hydroxide as a "caustic" to dissolve the fuel and chemically separate the uranium and plutonium. In the case of the INEEL RaLa Runs, lanthanum-140 or its decay product barium-140 was the production focus. At both sites there was little or no emission control systems in place to filter out the fission products like I-131 released to the atmosphere. "During this time, there no filters on the stacks of the separations plants. Radioactive materials in the form of gases, vapor, and particles went up the stacks. The separations process primarily released large amounts of iodine-131, ruthenium-106 and ruthenium-103 along with other radioactive substances. Two radioactive gases emitted in the separations process, krypton-85 and xenon-133, contribute to radiation dose of a person stands in a 'cloud' of the gases. Plutonium is also known to have traveled off-site." (5)
Because these other isotopes (besides I-131) contribute significantly to the dose, they must be included in the INEEL source terms at the Idaho Chemical Processing Plant (ICPP) now called INTEC. The RaLa Runs must also NOT be the sole focus of ICPP source terms, but rather one of many separations campaigns. Therefore, the entire ICPP throughput must be subjected to a full physical reconstruction. Just as important, is the high-level liquid waste Calciner incinerator and other high-level waste evaporators must be included in the ICPP source terms. The first Waste Calcine Facility came on line in 1963 and ran through 1981 incinerating more than 4 million gallons of high-level waste. The New Waste Calcine Facility (NWCF) operated between 1982 and 2000 incinerating an additional 4 million gallons of high-level liquid waste. (6) Both Calciners never received the required RCRA hazardous waste permits because they could not meet emission standards.
Again, ICPP stack monitoring data is unreliable and must not be used in source term estimation. To further illustrate this point, Environmental Defense Institute, Keep Yellowstone Nuclear Free, and David McCoy have copies of internal INEEL reports gained through a Public Information Request, that acknowledge as late as 1996 that the required ICPP stack monitors were either non-existent or were turned off. This document further acknowledges that DOE is in violation of the Clean Air Act (NESHAP) regulations. (7) DOE generates emission release documents based largely on "process knowledge" estimates, not on actual instrument monitoring data and is therefore unreliable not to mention illegal.
CDC is defending its resistance to a full physical reconstruction at INEEL, by characterizing it as only a "screening" process to determine if the RaLa Runs deserve additional study. CDC, in the past, forgot that "screening reviews " were quick and dirty reviews and later called them credible source terms studies in the hopes that no one remembers the applied methodology. The public demands credible science from CDC, and the agency must understand that we will not suffer through the same bogus process demonstrated at Hanford.
CDC's Phase-I document data base and the more recent RAC Task Order 6 database posted on the agency website was randomly checked for Hanford documents related to the INEEL RaLa Runs and other ICPP fuel reprocessing. None were found using the website search engine. Even Dr. Till's instructions to look for MC- 71617 and MC-71618 documents, the search came up empty. This is yet another indication that information base for the INEEL Dose Reconstruction Study remains deficient.
Attachment 4
Document Destruction
The issue of INEEL document destruction is at the crisis point. The recently released CDC status report on documents relevant to the INEEL Dose Reconstruction Study reveals that some 1,254 boxes of documents have been destroyed or are otherwise missing. A single box could hold 5,000 pages, so the total loss of information could be in excess of 6 million pages. One of the issues is the CDC's document classification system of Pertinence 1, 2, 3, and 9 in descending order of relative importance to the INEEL Dose Reconstruction Study. To illustrate the problem, let us use the example of the previously discussed need for a physical reconstruction of ICPP source terms. Since CDC never intended to do a physical reconstruction of the ICPP, documents related to reactor power level, cooling time, emission control systems would not be considered a high priority (pertinence 1 or 2) document. CDC's delays of over eight years to conclude its Phase -1 document review have given DOE ample opportunity to destroy incriminating evidence. The problem is so acute, that it is uncertain that a credible study can be done even if CDC suddenly found the political will to do good science. Independent researchers working on a future INEEL class action suit will face the same problem, because the essential information simply may no longer exist. CDC additionally failed to secure documents once identified so that they would be later available for use in the health study. That is like farmer Brown telling the fox which chickens are the fat ones and which roost they are on before turning over the keys to the fox to guard the chicken coop.
|
LOCATION |
PERTINENCE |
Phase I boxes |
Destroyed |
Recalled |
Reviewed |
Remaining |
Unable |
|
|
|
|
(total) |
|
|
|
|
to locate |
Total |
|
ANL-W Bldg 752 Records Retention |
1 |
9 |
2 |
|
7 |
|
|
9 |
|
ANL-W Bldg 752 Records Retention |
2 |
7 |
3 |
|
4 |
|
|
7 |
|
ANL-W Bldg 752 Records Retention |
3 |
169 |
8 |
|
161 |
|
|
169 |
|
ANL-W Bldg 752 Records Retention |
9 |
344 |
|
|
|
344 |
|
344 |
|
CFA Records Storage Facility Bldg 674E |
1 |
218 |
12 |
|
206 |
|
|
218 |
|
CFA Records Storage Facility Bldg 674E |
2 |
89 |
4 |
|
85 |
|
|
89 |
|
CFA Records Storage Facility Bldg 674E |
3 |
574 |
51 |
4 |
517 |
|
2 |
574 |
|
CFA Records Storage Facility Bldg 674E |
9 |
2707 |
556 |
37 |
4 |
2110 |
|
2707 |
|
LBC II |
1 |
1 |
|
|
1 |
|
|
1 |
|
LBC II |
2 |
6 |
|
|
6 |
|
|
6 |
|
LBC II |
3 |
2 |
|
|
2 |
|
|
2 |
|
LBC II |
9 |
2 |
|
|
2 |
|
|
2 |
|
NRF Bldg 627 |
1 |
148 |
7 |
|
131 |
|
10 |
148 |
|
NRF Bldg 627 |
2 |
32 |
8 |
|
24 |
|
|
32 |
|
NRF Bldg 627 |
3 |
199 |
15 |
|
175 |
|
9 |
199 |
|
NRF Bldg 627 |
9 |
96 |
|
|
11 |
85 |
|
96 |
|
Oak Ridge Operations Office Records Holding Area |
2 |
2 |
|
|
|
|
2 |
2 |
|
Oak Ridge Operations Office Records Holding Area |
3 |
2 |
|
|
|
|
2 |
2 |
|
Seattle National Archive Federal Records Center |
1 |
362 |
|
|
324 |
|
38 |
362 |
|
Seattle National Archive Federal Records Center |
2 |
443 |
48 |
|
393 |
|
2 |
443 |
|
Seattle National Archive Federal Records Center |
3 |
5294 |
426 |
31 |
4804 |
|
33 |
5294 |
|
Seattle National Archive Federal Records Center |
9 |
2006 |
|
|
156 |
1850 |
|
2006 |
|
TAN 607 Records Storage Vaults |
1 |
59 |
|
|
59 |
|
|
59 |
|
TAN 607 Records Storage Vaults |
2 |
2 |
|
|
2 |
|
|
2 |
|
TAN 607 Records Storage Vaults |
3 |
34 |
|
|
34 |
|
|
34 |
|
TAN 607 Records Storage Vaults |
9 |
253 |
|
|
1 |
252 |
|
253 |
|
|
All boxes |
13060 |
1140 |
72 |
7109 |
4641 |
98 |
|
|
|
Pert 1, 2, and 3 |
7652 |
584 |
35 |
6935 |
0 |
98 |
|
|
|
Pert 1 |
797 |
21 |
0 |
728 |
0 |
48 |
|
|
|
Pert 2 |
581 |
63 |
0 |
514 |
0 |
4 |
|
|
|
Pert 3 |
6274 |
500 |
35 |
5693 |
0 |
46 |
|
|
|
Pert 9 |
5408 |
556 |
37 |
174 |
4641 |
0 |
|
Attachment 5
Hanford FOIA Request
U.S. Department of Energy
Richland Operations Office
January 19, 1998
RE: Freedom of Information Act Request (RL-97-086)
Thank you for sending the Declassifications Requested by the Technical Steering Panel of Hanford Documents Produced 1944-1960 (PNWD-2024) pursuant to negotiations with the Office of Hearings and Appeals. The Hanford Public Reading Room sent a copy of the Hanford Site Originated Documents 1944-1960, Secret and Confidential Draft of Listed Hanford Site Originated Documents [PNL-10238]. These were helpful in clarifying the INEEL Research Bureau (IRB) FOIA request. The IRB is a project of the Environmental Defense Institute, Inc..
Attached please find a revised list to EDI September 4, 1997 FOIA list that provides a more accurate description of the requested documents.
Should you need further information concerning the INEEL Research Bureau's research program on this request please contact me by phone at 208-835-6152, in order to speed consideration of this matter.
Sincerely,
Chuck Broscious
Coordinator
cc:
IRB Member Organizations
Michael Sage, Center for Disease Control
INEEL Health Effects Subcommittee
Environmental Defense Institute FOIA to Hanford
As of 3/3/01 only 41 of the requested 158 documents were sent and all 41 were heavily censored to the extent that they were nearly useless.
HAN-40193 Project Bluenose Committee Experiments, 7/13/51
HAN-40477 Bluenose and other Matters, 7/27/51
HAN-40927 Project Bluenose Experiments, Cook, 9/7/51
HAN-40953 Status of Project Bluenose, Holsted, 8/22/51
HAN-41268 Project Bluenose Experiments, 10/4/51
HAN-41861 Shipment of Irradiated J Slugs to Arco, 11/15/51
HAN-42440 Downtime for Project Bluenose, 1/4/52
HAN-42448 Idaho CPP startup materials, 12/29/51
HAN-42692 Idaho CPP Start-Up Materials, 1/14/52
HAN-42758 Canning special slugs for Arco, 1/16/52
HAN-42842 Processing J slugs at Arco, 1/24/52
HAN-42861 Shipment of Irradiated slugs to Arco
HAN-43290 Idaho CPP Startup Material, 2/19/52
HAN-43373 Canning Special Slugs for Arco, 2/27/52
HAN-44407 Project Bluenose Discussions at Argonne Nat. Lab., 4/10/52, 4/10/52
HAN-44439 Bluenose 5/2/52
HAN-45259 Bluenose Data, 6/20/52
HAN-45263 Project Bluenose Experiments
HAN-45268 Bluenose Experiment Analytical Samples, 6/18/52
HAN-45269 Bluenose Experiment Analytical Samples, 6/19/52
HAN-45274 Calculations and Transmittal of Krypton Release Data, 6/24/52
HAN-46940 Bluenose Experiment Analytical Results, 10/8/52
HAN-47812 ARCO Separations Plant, 11/26/52
HAN-50465 Bluenose dissolving data, 5/22/53
HAN-50467 Measurement of SF material content of irradiated J slugs at Idaho
CPP, 5/20/53
HAN-50518 Bluenose releases, 5/28/53
HAN-50693 Review of Bluenose Chemical Analyses, 6/1/53
HAN-50767 Bluenose Analytical meeting at ORNL May 21& 22, 1953, 6/3/53
HAN-50838 Project Bluenose meeting, June 12, 1953, 6/19/54
HAN-50834 Bluenose experiment analytical results
HAN-50858 Forecast of slugs shipments to Arco, 6/23/53
HAN-50951 Bluenose Experiment Analytical Results, 6/23/53
HAN-51111 Bluenose Analytical Results-V, 7/2/53
HAN-51053 Shipments to Arco, 7/8/53
HAN-51152 Bluenose analytical results
HAN-51167 Bluenose results, 7/17/53
HAN-51295 Calculations and evaluations of Bluenose results, C.A.Bennet, 7/24/53
[HW-28814]
HAN-51294 Statistical analysis of project Bluenose uranium results, 7/22/53
HAN-51552 Calculations & Evaluations of Bluenose Results, 8/11/53
HAN-51617 Calculations & Evaluations of Bluenose Results, 8/19/53
HAN-51624 Calculations and evaluations of Bluenose results, 8/19/53
HAN-52662-1 Forecast monthly shipments to ICPP, 11/13/53
HAN-52662 Forecast of Spent Fuel Shipments from Hanford and Savannah River to
ICPP 1954 through 1955, 11/9/53
HAN-52743 Shipments of Irradiated Enriched Uranium from Hanford to ARCO,
11/17/53
HAN-52804 Calculations of KR-85 Releases, Bennett, 11/23/53
HAN-52865 Forecast of Spent Fuel Shipments from Hanford to ICPP, 12/1/53
HAN-53114 Bluenose Experiment Data (Kinderman), 12/22/53
HAN-53121 Shipments of Irradiated Enriched Uranium from Hanford to ARCO,12/21/53
HAN-53403 Statistical Analysis of Project Bluenose P Result (Tingey), 12/23/53
HAN-53691 Off Gas Approval at Idaho CPP (English), 2/5/54
HAN-53725 Shipment of Irradiated J Slugs from Hanford to Arco, 2/10/54
HAN-53734 Shipment of Irradiated Enriched Uranium to Arco, 2/10/54
HAN-53823 Shipment of Irradiated J Slugs from Hanford to Arco, 2/18/54
HAN-53842 Krypton Releases from Idaho (Kavanagh), 2/15/54
HAN-53915 RaLa Program, 2/26/54
HAN-53928 Shipment of Irradiated J Slugs from Hanford to Arco, 2/23/54
HAN-53988 Bluenose Program (Sturges), 3/1/54
HAN-54022 Criticality Considerations for ICPP Modifications, 3/5/54
HAN-54096 Bluenose Program, 3/10/54
HAN-54108 Shipment of Irradiated Enriched Uranium to Arco, 3/12/54
HAN-54190 Off-gas Removal at Arco Chemical Plant, 3/16/54
HAN-54190-1 Release of Krypton 131 & 133 [sic] from Proposed Increased
Production at CPP, 2/10/54
HAN-55305 Design basis for ICPP modifications, 6/7/54
HAN-55522 Transmittal of Bluenose Documents, 6/29/54
HAN-55621 Constants for Bluenose Data, 7/8/54
HAN-56557 Scheduling RaLA Shipments, 7/30/54
HAN-56895 Project Bluenose Future Plans, 10/27/54
HAN-57146 Bluenose Slug Experiment, 10,21,54
HAN-57773 ICPP Experience with Extruded J Slugs, 1/12/55
HAN-57773-1 ICPP Experience with Extruded J Slugs, 12/1/54
HAN-57932 Forecast of Loads for ICPP, 2/3/55
HAN-58009 History of Hanford Slugs Processed at ICPP During Jan 1955, 2/10/55
HAN-58025 Shipment of J Slugs to Arco, 2/10/55
HAN-58154 Shipment of J Slugs to Arco, 2/28/55
HAN-58223 Accuracy of Bluenose Experiment, 3/4/55
HAN-58264 Preparation of ICP release data, 3/9/55, Bennett, [HW-35693]
HAN-58488 Preparation of ICP Release Data, 3/18/55
HAN-58724-1 Idaho Chemical Processing Plant Unit Processing Cost Data, 1/14/55
HAN-58908 Transmittal of ICPP Cost Data, 4/26/55
HAN-59174 Review of Bluenose Program, 5/26/55
HAN-59246 Recommendation of Slugs for Dissolution Project Bluenose, Bennett,
6/2/55
HAN-59297 Bluenose Experimental Cost, 6/8/55
HAN-59448 Selection of Slugs for Bluenose and Related Programs, 6/22/55
HAN-59467 Selection of Slugs for Bluenose and Related Programs, 6/22/55
HAN-59635 Calculations of Idaho Releases, 7/14/55
HAN-59635-1 Calculations of Idaho Krypton & Xenon Releases, 7/14/55
HAN-59663 Shipment of Bluenose Slugs, 7/19/55
HAN-59957 Statistical Aspects of the Analytical Program for Bluenose Slugs,
7/22/55
HAN-60324 Calculations & Reporting of Hanford & ICPP Releases, 9/22/55
HAN-60656 ICPP releases, 10/28/55, C.A. Bennett
HAN-60658 Americium-Curium Correction in Bluenose P Assay, 10/14/55
HAN-60987 Hanford Material Processed at CPP, NRTS, 12/8/55
HAN-61431 Selection of Slugs for Bluenose Related Programs, 1/1/56
HAN-61434 Selection of Slugs for Bluenose Related Programs, 1/31/56
HAN-61693 Idaho Releases from Hanford Materials, 2/28/56
HAN-61940 J and C Slugs Shipments to the ICBP, 3/26/56
HAN-62172 Shipment of ruptured C and J Slugs to Arco, 4/18/56
HAN-62447 Calculations of Bluenose Releases, 5/15/56
HAN-62451 Reporting Bluenose Releases, 5/15/56
HAN-62452 Shipment of Bluenose Experimental Slug Samples, 5/14/56
HAN-62661 Bluenose release calculations 6/8/56
HAN-62842 Bluenose Releases at Idaho, 6/27/56
HAN-62850 Reporting Bluenose Releases, 6/28/56
HAN-62997 Gaseous Fission Product Release, 7/20/56
HAN-62998 Bluenose releases at Idaho 7/20/56
HAN-63118 ICPP Release Data, J. Jaech, 8/3/56
HAN-63167 Bluenose releases at Idaho 8/7/56
HAN-63190 Reporting Bluenose releases 8/10/56
HAN-63257 Reporting Bluenose Releases, 8/16/56
HAN-63257-1 Gaseous fission product release , 8/10/56
HAN-63384 Gaseous fission Product released (VA-142-56A), 8/6/56
HAN-63432 Thorex Bluenose Releases, 9/6/56
HAN-63460 ICPP releases of Hanford Material July 1956, J. Jaech, 9/14/56
[HW-45549]
HAN-63536 Summary of ICPP KR-85 Releases, 9/19/56
HAN-63536-1 Summary of ICPP Releases July 1955 - June 1956 9/18/56
HAN- 63536-2 SRP Materials Processed at Arco, 9/19/56
HAN-63584 Hanford Slugs released to ICPP, Bennett, 9/27/56
HAN-63609 Comparison of HPO and ICPP Release of #Curies for Hanford Irradiated
Material Dissolved at ICPP, J. Jaech, 9/28/56, [HW-45721]
HAN-63688 Reporting Bluenose releases , 10/8/56
HAN-63688-1 Gas Release Report, 9/20/56
HAN-63688-2 Gas Release Report, 9/20/56
HAN-63813 Reporting Bluenose releases, 10/22/56
HAN-63997 Shipments to the ICPP, 11/13/56
HAN-64284 Reporting Bluenose Releases, 12/17/56
HAN-64284-1 Gas Release Report, 11/19/56
HAN-64357 Reporting Bluenose releases 12\21\56
HAN-64357-1 Gas Release Report, 12/14/56
HAN-64366 ICPP releases of Hanford Material Aug-Sept 1956, 12/21/56,[HW-47595]
HAN-64978 ICPP Releases of Hanford Material, J. Jaech, 3/7/56 [HW-48912]
HAN-66781 Excerpt HAN 53824-1 Krypton release from Idaho, 2/16/54
HAN-68946 C & J Shipments to ICPP, 5/8/58
HW-30440 Statistical Analysis of Project Bluenose Plutonium Result, F. Tingely,
2/23/53
HW-31217 Trip Report visit to Arco, Idaho Installation, R.Bursey, 3/23/54
HW-36076 A compendium of Hanford efforts in support of Bluenose, A.Dunbar, 4/12/55
HW-37030 Recommendation of slugs for dissolution project Bluenose
HW-39688 ICPP Releases, C.Bennett, 10/28/55
HW-44796 ICPP Release Data, J.Jaech,8/3/56
HW-45549 ICPP Release of Hanford Material July 1956, J. Jaech, 9/14/54
HW-45721 Comparison of HAPO and ICPP Release Figures for Hanford, J. Jaech, 9/28/56
HW-47595 ICPP Releases of Hanford Material, August - September 1956, J. Jaech,
12/21/56
HW-49584 Idaho release Calculations for January 1957, J.Jaech, 4/9/57
HW-52265 Summary of ICPP Releases of HAPO irradiated material, July 1956 - June
1957 J. Jaech, 8/26/57
HW-53307 Authorization of Expenditures Project Bluenose AEC, H.Parker, 10/22/57
HW-56232 Idaho Release Calculations through March 1958, J.Jaech, 6/3/58
HW-61661 Iodine Release Information, H. Parker, 8/26/59
Endnotes
1. Hoffman, F. Owen, Evaluation of the HEDR
Source Term and HTDS Power Calculations, SENES Oak Ridge Inc., Center for
Risk Analysis, March 1999. Also see email from Hoffman to Broscious 9/6/00.
Hoffman adds, stack monitoring data can be fraught with uncertainty, especially
if the samplers are inefficient and not isokinetic. I agree, the releases
should best be based on process level modeling followed by environmental
sampling of I-129 (to confirm the release fractions). Was RaLa the only source
of I-131 releases at INEEL? At Oak Ridge it may not have been. I now think that
the total releases of I-131 were underestimated at Oak Ridge. At INEEL, the
public health implications of exposure to releases of I-131 must consider the
combined exposures to I-131 in Nevada Test Site and global fallout as well. In
fact, worker exposures and risks should be considered along with those residing
offsite.
2. Scheduling RaLa Shipments, July 30, 1954, General
Electric Company, Hanford Atomic
Products Operation. HW-32594, HAN-56557
3. See HAN 53823
4. See HAN -52865
5. Hanford Health Information Network, The Release of
Radioactive Materials from Hanford: 1944- 1972, April 1993
6. Idaho High-Level Waste and Facilities Disposition Draft
Environmental Impact Statement December 1999, Vol. 4, C.9-11.
7. DOE Notegram, July 25, 1996, to C. L. Tellez, from M. E.
Feldman and T. A. Solle, Subject "Air " Legacy Issues